About this Notice

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event that you have a query or complaint.

The University of Warwick (“UoW”) is committed to protecting the privacy and security of personal data. The purpose of this notice is to promote transparency in the use of personal data, and to outline how UoW collects and uses personal data during and after your working or visiting relationship with us, in accordance with the General Data Protection Regulation 2016 (“GDPR”) and the Data Protection Act 2018 (“DPA 2018”).

The UoW collects, uses and is responsible for certain personal data about you. This is known as “processing”. When we do so we are regulated under the GDPR and DPA 2018 which applies across the European Union and we are responsible as ‘data controller’ of that personal data for the purposes of those laws.

The purpose of this notice is to explain how the University of Warwick (“UoW”) will collect and use (process) your personal data, what rights you have in relation to that data and to provide transparency about the data collected about you.

The UoW is the data controller under the GDPR and DPA 2018 and we will process your personal data in accordance with the GDPR and DPA 2018 at all times. You, as a ‘data subject’, therefore have specific rights to the data that we hold, collect and process.

Throughout this notice, “University”, “we”, “our”, and “us” refer to the University of Warwick; “you” and “your” refer to students, job applicants, employees, (current and former), workers (including agency), apprentices, interns, work experience and volunteers, contractors, honorary/ visiting associates.

If you would like this notice in another format (for example: audio, large print, braille), please contact us (see ‘How to contact us’ above).

The personal data we collect and use

The following are examples of personal data which may be collected, stored and used:

Right to Rent details such as; Passport or ID Cards, Visa, Employment Status

Health records Disabilities

Complaints and Appeals

Special Category Data:

Special Category personal data is any identifying information including but not limited to the following racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning health or data concerning a natural person’s sex life or sexual orientation

How the Univeristy of Warwick obtains your personal data

Your personal data is typically collected when you complete the UoW admissions processes and register as a student, when you complete the accommodation application process, directly from you via face-to-face meetings, from telephone discussions, email or other forms of online submissions by you. Images of you may be gathered from CCTV recordings. Further information may be obtained from third parties such as the Home Office, Students Loan Company and UCAS.

Purpose and associated lawful basis

Your personal data will be processed by the UOW for the purposes outlined below:

Purpose

Lawful Basis

Facilitate the application process for accommodation.

Performance of a contract.

Reviewing the initial application for accommodation and requesting any further information from you.

Performance of a contract.

Communicating with you about your accommodation application and allocation.

Performance of a contract.

Allocating accommodation to you.

Performance of a contract.

Considering any special requests regarding the accommodation allocation and obtaining any additional further information in relation to the requests.

Performance of a contract.

Liaising with the Residential Life, Off Campus, Staff and Family Housing, Estates and Student Reception to facilitate any special requests for the provision of accommodation in line with your requirements.

Performance of a contract.

Taking any payment in relation to accommodation contract.

Performance of a contract.

To provide suitable support to you whilst you are living in UoW accommodation which may include liaising with other parts of the UoW.

Performance of a contract.

Administering the contract the University has entered into with you.

Performance of a contract.

Business management and planning, including accounting and auditing.

Compliance with a legal obligation and/or legitimate interest of sound management of the business of the University.

To prevent fraud.

Compliance with a legal obligation.

Ensuring the safety and security of UoW students, staff and third parties instructed on their behalf.

Compliance with a legal obligation.

Ensuring the safety and security of UoW property.

Compliance with a legal obligation.

Research and statistical analysis.

Legitimate interest of the University.

Communicating with you regarding general accommodation matters

Performance of a contract and Legitimate interest of the University

Facilitate the postal service provided by the University

Legitimate interest of the individual

Use of Special Category Data:

UoW wishes to assist any student who has specific requirements in obtaining accommodation that meets their needs. In order to do so, it is necessary for UoW to process a limited amount of personal data relating to your health and medical data so that an assessment of your eligibility can be made and your needs can be met.

UoW will only process Special Category Data where you have provided your consent to do so during the enrolment process and/or you have included such within your accommodation application, unless UoW are otherwise legally obliged.

UoW will process Special Category Data to establish a person’s Right to Rent so that an assessment of your eligibility can be made.

If you do not wish for UoW to process your Special Category Data for the purposes of administering your accommodation contract, please email Allocations@warwick.ac.uk.

Please note: there may be certain circumstances where the processing of medical/health data is required for social security/protection requirements, protecting your vital interest and/or for reasons of substantial public interest or where the information has been made public to you. UoW will not require your consent in these circumstances.

Where we believe it is necessary to protect your vital interests, we may share your personal data with the Wellbeing Support Team (we refer you to their Privacy Notice) and the Residential Life Team within the UoW.

Lawful bases for processing your personal data under the GDPR and DPA 2018

Personal data will only be processed when the law permits this to happen. Most commonly personal data will be processed in the following circumstances:

Where you have given us your consent

In order to fulfil UoW’s obligations to you as part of a contract

Where UoW needs to comply with a legal obligation (for example, the detection or prevention of crime and financial regulations)

Where it is necessary for UoW’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

To protect the vital interests of the data subject or of another person (for example, in the case of a medical emergency)

In order to perform a task carried out in the public interest

UoW will only use personal data for the purposes for which it was collected unless it is considered reasonable that it is needed for another purpose and the reason is compatible with the original purpose. If the University needs to use your personal data for an unrelated purpose, it will notify you and will explain the legal basis that permits it to do so. The University may process your personal data without your knowledge or consent, in compliance with this policy and procedure, where this is permitted by law.

In limited circumstances UoW may contact you for your written consent to the processing of particularly sensitive data. In such circumstances UoW will provide you with full details of the information needed and the reason it is needed, so that you can consider whether you wish to give your consent.

Where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Individuals need to write to infocompliance@warwick.ac.uk to withdraw their consent. Once UoW has been notified that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If the latter is the case we will inform you of this legitimate basis.

Data Sharing

UoW may share your personal data with third parties where required by law, where it is necessary to administer the contractual relationship with you or where there is another legitimate interest in so doing including, but not limited to, for joint appointments with other external organisations. Third parties with whom we may share your data include:

Third parties within the EEA

Lawful basis

HMRC

Compliance with a legal obligation

Local Authorities

Compliance with a legal obligation

Utility Providers

Performance of a contract

Government Departments

Compliance with a legal obligation

Third Party Contractors

Consent

Private Providers of Accommodation

Performance of a contract

Approved Property Owners

Performance of a contract

Retention of your personal data

The GDPR and DPA 2018 require that personal data should be kept for no longer than is necessary for the purposes for which the personal data are processed (except in certain specific and limited instances).

The University’s Record Retention Schedule (RRS) is a tool that enables the University to transparently demonstrate how the organisation complies with its data protection obligations by making provision for the time periods for which common classes of record are retained by UOW.

Full details of the retention periods of records can be found by viewing the records management page and selecting the University’s Record Retention Schedule (RRS), which is kept up to date separately.

Data subject requests

Under the GDPR and DPA 2018 you have a number of important rights free of charge.

You have the right to:

Be informed of how we collect and use your personal data;

Access your personal data;

Require us to correct any mistakes in the data we hold on you;

Require the erasure of personal data concerning you in certain situations;

Receive your personal data, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;

Object in certain situations to our continued processing of your personal data or at any time to processing of your personal data for direct marketing; and

Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.

To exercise any of these rights please find out more here. If a subject access request is made and the request for access is clearly unfounded or excessive, the University reserves the right to refuse to comply with the request in these circumstances.

Keeping your personal data secure

The UoW keeps your personal data secure at all times using both physical and technical measures.

Where appropriate, we also take measures such as anonymisation to ensure data cannot be used to identify you and/or encryption to ensure that the data cannot be accessed without the right security accesses and codes.

Where UoW engages a third party to process personal data it will do so on the basis of a written contract which conforms to the security requirement of the GDPR and DPA 2018.

UoW takes measures to enable data to be restored and accessed in a timely manner in the event of a physical or technical incident.

UoW also ensures that we have appropriate processes in place to test the effectiveness of our security measures.

How to contact us

We hope that our Data Protection Officer (DPO) can resolve any query, concern or complaint you raise about our use of your personal data on the contact details below:

Ms Anjeli Bajaj (DPO) can be contacted via e-mail at infocompliance@warwick.ac.uk
Or write to:
The Data Protection Officer
Information and Data Compliance Team
University of Warwick
University House
Kirby Corner Road
CV4 8UW

The GDPR and DPA 2018 also gives you the right to lodge a complaint with the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].

Changes to this Privacy Notice

This privacy notice was published on 05/11/2018. We may change this privacy notice from time to time, when we do so we will inform you via e-mail.